Eqia Report Template s2

EQUALITY IMPACT ASSESSMENT

REVIEW OF STREET LIGHTING OPTIONS

September 2015

This document is available in other formats, please contact [email protected] or telephone 03000 421553

Updated 17/09/15 1 KENT COUNTY COUNCIL EQUALITY IMPACT ASSESSMENT

Directorate:

Growth, Environment and Transport

Name of policy, procedure, project or service:

Review of Street Lighting Options

What is being assessed?

Kent County Council are looking to replace all of its street light lanterns with Light Emitting Diode (LED) technology and control these remotely using a Central Management System (CMS).

The CMS coupled with LED technology will allow individual street lights or groups of street lights to be turned off or on, dim the brightness of the light and also to monitor the amount of energy being used.

Once all of the street lights have been upgraded to LED technology and CMS has been installed, this will give Kent County Council greater flexibility in delivering its street lighting service and enable it to change its current street lighting policy (see Appendix A).

Kent County County will then have two options:

Option 1 - Continue with ‘Part-Night Lighting’ across Kent for lights that do not meet the exclusion criteria as detailed under ‘Areas where street lighting has not been switched off’ (on page 12). This means Kent County Council owned street lights are switched off in selected areas between 12 midnight and 5.30am during winter, or 1am and 6.30am during summer.

Kent County Council also has an additional option of dimming the brightness of all selected street lights that are left switched on during late evenings/early mornings.

Option 2 – Have ‘All-Night Lighting’ across Kent, which means Kent County Council owned street lights are kept switched on all night long.

Kent County Council also has an additional option of dimming the brightness of all street lights in Kent that are switched on late evenings/through the night/early mornings.

This Equality Impact Assessment looks at the impact of Option 1 and Option 2 on Project Characteristics.

Updated 17/09/15 2 Responsible Owner/ Senior Officer

Roger Wilkin, Interim Director (Highways, Transportation & Waste)

Date of Initial Screening:

03/07/15

Date of Full EqIA:

A public consultation will take place between 21 September and 29 November 2015, asking the people of Kent their thoughts and views on Option 1 and Option 2.

This EqIA will then be updated once the public consultation has finished and the consultation results are available. The full impact assessment will take into account the analysis by Protected Characteristics.

The consultation results will then be reviewed by Kent County Council’s Cabinet Committee and they will choose either Option 1 or Option 2 to shape a new Kent County Council street lighting policy which will replace its old one. Whichever Option is chosen will then be applied county-wide to all Kent County Council owned street lights.

Other EqIAs:

Once Cabinet Committee have reviewed the results of the consultation and a decision been made by them to go with either Option 1 or Option 2, their decision will then be used to inform the new street lighting policy.

A separate Equality Impact Assessment will need to be written on this new street lighting policy and any impact it will have on Protected Characteristics.

Record of changes to this Equality Impact Assessment

Version Author Date Comment 2 Iain Norman 10/08/15 First draft for review by Rob Clark and Akua Agyepong 3 Akua Agyepong 27/08/15 Comments made on first draft 4 Iain Norman 08/09/15 Revised version for review by Rob Clark following comments made by EqIA team 5 Akua Agyepong 17/09/15 Comments made on sedond draft 6 Iain Norman and 18/09/15 Revised version for review by Rob Clark Anne Wynde following comments made by EqIA team

Updated 17/09/15 3 Initial Screening Assessment – Option 1: Part-Night Lighting i.e. Selected street lights are switched off between the hours of 12 midnight and 5.30am (Greenwich Mean Time) or 1am and 6.30am (British Summer Time), with additional options for those street lights left on to dim during late evenings/early mornings).

Provide details: Could this policy, procedure, Could this policy, Assessment of a) Is internal action required? If yes what? project or service promote procedure, project or potential impact b) Is further assessment required? If yes, equal opportunities for this service, or any proposed HIGH/MEDIUM why? group? Protected changes to it, affect this LOW/NONE YES/NO - Explain how good Characteristic group less favourably UNKNOWN than others in Kent? practice can promote equal YES/NO opportunities If yes how? Positive Negative Internal action must be included in Action If yes you must provide detail Plan

a) No. Street lights will not be turned off at night outside of sheltered housing, other residences accommodating vulnerable people, formal pedestrian crossing, subways and enclosed Yes. Any impact from footpaths and alleyways where one end links street lights being to a road that is lit all night, or areas with a 24 switched off or dimmed hour operational emergency service such as Age late at night will be in None Low hospitals and nursing homes. These locations n/a respect to mobility or were identified as part of the Part-Night where personal safety is Lighting project as being considered not an issue. suitable for part-night lighting (see ‘Areas where street lights have not been switched off’).

Gender No None None

Gender identity No None None

Race No None None

Updated 17/09/15 4 a) No. Street lights will not be turned off at night outside of sheltered housing, other residences Yes. Any impact from accommodating vulnerable people, formal street lights being pedestrian crossing, subways and enclosed switched off or dimmed footpaths and alleyways where one end links late at night will be in Disability None Low to a road that is lit all night, or areas with a 24 n/a respect to mobility or hour operational emergency service such as where personal safety is hospitals and nursing homes (see ‘Areas an issue . where street lights have not been switched off’).

a) Yes. Further information is required on whether or not ‘Religion or belief’ is seen as a Protected Characteristic that will be impacted upon disproportionality should street lights be turned off at places of worship late at night.

b) Yes. If any location or area has been identified during the consultation (which once Option 1 or Option 2 has been chosen) which by turning off street lights at night has an impact Yes. Those who use on ’Religion or belief’, then Kent County places of worship late at Religion or belief None Low Council will need to carry out an assessment n/a night where personal to identify who owns the street lighting in that safety is an issue area (i.e. whether the street lights are owned by Kent County Council, the local Parish or Town Council, Borough or District Council or privately owned). If the street light is Kent County Council owned, then places of worship could be considered to be added to the list of places outside which lights would not be turned off (see ‘Areas where street lights have not been switched off’).

Updated 17/09/15 5 Sexual orientation No None None

a) No. Street lights will not be turned off at night outside of sheltered housing, other residences accommodating vulnerable people, formal pedestrian crossing, subways and enclosed footpaths and alleyways where one end links Pregnancy and to a road that is lit all night, or areas with a 24 No None None n/a maternity hour operational emergency service such as hospitals and nursing homes (see ‘Areas where street lights have not been switched off’).

Marriage and Civil Partnerships No None None

a) No. Street lights will not be turned off at night outside of sheltered housing, other residences accommodating vulnerable people, formal pedestrian crossing, subways and enclosed footpaths and alleyways where one end links Carer’s to a road that is lit all night, or areas with a 24 No None None n/a responsbilities hour operational emergency service such as hospitals and nursing homes (see ‘Areas where street lights have not been switched off’).

Updated 17/09/15 6 a) Yes. Any locations or areas identified during the consultation which aren’t currently on the list of places where street lights are kept on all night (see ‘Areas where street lights have not been switched off’) or will have an impact through dimming, will need to be reviewed Yes. There maybe following a decision by Cabinet Committee to locations or areas not go with either Option 1 or Option 2. currently identified where street lighting will not be b) Yes. If any location or area has been identified switched on at night or during the consultation (which once Option 1 dimmed, which may then or Option 2 has been chosen) which by All Protected impact on All Protected turning off street lights at night or dimming has Characteristic None Low n/a Characteristics. an impact on all Protected Characteristics, groups then Kent County Council will need to carry Any impact from street out an assessment to identify who owns the lights being switched off or street lighting in that area (i.e. whether the dimmed late at night will street lights are owned by Kent County be in respect to mobility or Council, the local Parish or Town Council, personal safety. Borough or District Council or privately owned). If the street light is Kent County Council owned, then these locations or areas could be considered to be added to the list of places outside which lights would not be turned off (see ‘Areas where street lights have not been switched off’).

Updated 17/09/15 7 Initial Screening Assessment – Option 2: All-Night Lighting (with additional options for dimming during late evenings/early mornings).

Could this policy, Assessment of Provide details: Could this policy, procedure, project procedure, project or potential impact a) Is internal action required? If yes what? or service promote equal service, or any proposed HIGH/MEDIUM b) Is further assessment required? If yes, opportunities for this group? Protected changes to it, affect this why? LOW/NONE YES/NO - Explain how good practice Characteristic group less favourably UNKNOWN can promote equal opportunities than others in Kent? YES/NO Positive Negative Internal action must be included in Action If yes you must provide detail If yes how? Plan Age No

Disability No

Gender No

Gender identity No

Race No

Religion or belief No

Sexual No orientation

Pregnancy and maternity No

Marriage and Civil Partnerships No

Carer’s No responsbilities

Updated 17/09/15 8 c) Yes. Further information is required on whether or not ‘All Protected Characteristics’ will be impacted upon disproportionality should street lights be dimmed late at night. Yes. There maybe This information will come from the public locations or areas not consultation, specifically the analysis by currently identified where Protect Characterisics. dimming of street lighting late at night or early a) Yes. If a particular location or area has been morning may have an identified during the consultation (which once All Protected impact on All Protected Option 1 or Option 2 has been chosen) which Characteristic Characteristics. None Low by dimming street lights at night has an impact n/a groups on all Protected Characteristics, then Kent Any impact from street County Council will need to carry out an lights being dimmed late assessment to identify who owns the street at night or early morning lighting in that area (i.e. whether the street will be in respect to lights are owned by Kent County Council, the mobility or personal local Parish or Town Council, Borough or safety. District Council or privately owned). If the street light is Kent County Council owned, then these locations or areas could be considered as part of a list of places outside which street lights will not be dimmed.

Updated 17/09/15 9 Part 1: INITIAL SCREENING (August 2015)

Proportionality

Low Medium High Low relevance or Medium relevance or High relevance to Insufficient information / Insufficient information / equality, / likely to have evidence to make a evidence to make a adverse impact on judgement. Judgement. protected groups

Option 1: Part-Night Lighting

(i.e. selected Kent County Council owned street lights are switched off between 12 midnight and 5.30am during winter, or 1am and 6.30am during summer, with the option to dim the brightness of those lights remaining switched on during late evenings/early mornings).

State rating & reasons

Based on the results from the initial screening assessment, the number of people potentially affected by Option 1: Part-Night Lighting will be more than 501. This gives a score of 4 on the Risk Rating Matrix.

Using the Risk Rating Matrix, a likelihood of ‘Possible’ and risk rating of ‘Moderate Impact’, combined with the score of 4 (for number of potential people affected) gives an overall score of 10 points which gives Option 1: Part-Night Lighting as having a ‘Medium Impact’.

Option 2: All-Night Lighting

(i.e. all Kent County Council owned street lighting are kept switched on all night long, with the option to dim the brightness of these lights during late evenings/early mornings).

State rating & reasons

Based on the results from the initial screening assessment, the number of people potentially affected by Option 1: All-Night Lighting will be more than 501. This gives a score of 4 on the Risk Rating Matrix.

Using the Risk Rating Matrix, a likelihood of ‘Unlikely’ and risk rating of ‘Minor Impact’, combined with the score of 4 (for number of potential people affected) gives an overall score of 6 points which gives Option 1: Part-Night Lighting as having a ‘Medium Impact’.

Updated 17/09/15 10 Context

Legal requirement by Kent County Council

Where street lighting is provided, Kent County Council is under a duty of care to ensure that it is maintained in accordance with all its legal obligations and that it adheres to professional guidance and good industry practice.

Kent County Council is required to maintain any street lighting it does provide in a safe condition for the benefit of the community it serves.

On the 1 April 1967, under the provisions of the Local Government Act 1966, Kent County Council assumed responsibility for the maintenance and operation of highway lighting throughout the County generally, including the provision of new installations.

District Councils also have the power to provide lighting as local lighting authority under the powers of the Public Health Act 1985.

Where District, Town or Parish Councils wish to provide lighting on a highway the consent of Kent County Council, as Highway Authority, is required.

The Highways Agency is the Highway Authority for road lighting on Trunk Roads and motorways, and will have its own policies and practices for the maintenance of those installations.

Introduction of Part-Night Lighting in 2013

Between December 2013 and autumn 2014, part-night lighting was introduced following extensive discussion, debate and a 3 month public consultation.

Approximately 60,000 street lights, which is about half of the lights Kent County Council own, now turn off for part of the night. These are located mainly in residential and minor roads.

This means that all Kent County Council owned street lights are switched off between 12 midnight and 5.30am during winter (GMT or Greenwich Mean Time) and between 1am and 6.30am during summer (BST or British Summer Time)

Some Parish and District Councils maintain their own lights and so these aren’t included in the part-night lighting scheme.

If you would like to see whether the street lights in your street have part-night lighting you can do this using your post code via the online map at the following website link: link to street lights map

Updated 17/09/15 11 Areas where street lights have not been switched off

The following locations were considered not being suitable for part-night lighting and so the street lights have not been switched off at night time:

. Sites of potential road safety concerns . On some main traffic routes . Town centres . Locations with a significant night-time traffic record between about midnight and 5.30am winter time (1am to 6.30am summer time) . Areas identified by the police . Areas provided with local authority or police CCTV surveillance equipment . Areas with sheltered housing and other residences accommodating vulnerable people . Areas with a 24 hour operational emergency services site including hospitals and nursing homes . Formal pedestrian crossings, subways and enclosed footpaths and alleyways where one end links to a road that is lit all night . Where road safety measures are in place on the highway

(note: the word ‘vulnerable’ used in the above list is hard to define and depends really on each individuals particular circumstances in relation to part- night lighting).

Aims and Objectives

The aims and objectives of this street lighting project are to:

 Reduce energy consumption by around 60%  Reduce carbon emissions by around 60%  Reduce light pollution  Make annual savings of around £5.2m (at today’s prices)

The key steps to making this happen are:

1. Upgrade all of Kent County Councils current stock of 120,000 street lights to light emitting diode (LED) technology 2. Install a computerised Central Management System (CMS) 3. A public consultation on Option 1 (Part-Night Lighting) and Option 2 (All-Night Lighting) with additional options to dim the brightness of street lights lit late at night 4. A change in Kent County Council’s current street lighting policy following Cabinet Committee’s review of the public consultation results around Option 1 or Option 2 5. Put into action either Option 1 or Option 2 following Cabinet Committee’s decision

Updated 17/09/15 12 Beneficiaries

The table below shows a list of benefits should Option 1 be chosen.

Benefits to Protected Benefits to Protected Characteristics if Option Characteristics if Option Protected Characteristic 1: Part-Night Lighting is 1: Part-Night Lighting is chosen, with additional chosen options for dimming. Age None None Disability None None Gender None None Gender Identity None None Race None None Religion or belief None None Sexual orientation None None Pregnancy/maternity None None Managing Civil Partnerships None None Carers responsibilities None None All Protected Characteristic None None groups

The table below shows a list of benefits should Option 2 be chosen.

Benefits to Protected Benefits to Protected Characteristics if Option 2: Characteristics if Option Protected Characteristic All-Night Lighting is 2: All-Night Lighting is chosen, with additional chosen options for dimming. Age Disability Gender Gender Identity Race Religion or belief

Updated 17/09/15 13 Sexual orientation Pregnancy/maternity Managing Civil Partnerships Carers responsibilities Roads, pavements, Roads, pavements, footpaths and access footpaths and access routes lit up late at routes are dimmed and so night, meanining are partially lit up late at All Protected Characteristic travelling through these night, meaning travelling groups areas is easier from a through these areas is mobility point of view as easier from a mobility point well as a greater sense of view as well as a of personal safety in greater sense of personal relation to crime. safety in relation to crime.

Information and data

The people of Kent interact with street lighting we believe on a location-by- location basis. For example, elderly patients that live in the Tunbridge Wells region in most part generally use the Accident & Emergency Services at Pembury Hospital and interact with Kent County Council’s street lighting at the entrance & exits to this hospital.

To help us understand how people generally interact with street lighting on a daily basis, we carried out a desktop exercise (see Appendix B). In this exercise; we looked at different locations and considered what times of the day those locations were approximately open until, so we have an idea of whether or not they are there’s a potential for people visiting those locations late at night to be impacted on by part-night lighting/dimming.

We then carried out a second desktop exercise (see Appendix C). In our second desktop exercise, we looked at the same locations as the first exercise (as well as the times of the day those locations were approximately open until) then considered whether any of the 10 Protected Characteristics such as Age, Gender etc. were potentially affected by Option 1: Part-Night Lighting or Option 2: All-Night Ligthing. We then used the findings from our second desktop exercise to inform the initial screening assessment.

For our initial screen assessment regarding the impact of Option 1: Part-Night Lighting on Protected Characteristics, we also referred to a previous Equality

Updated 17/09/15 14 Impact Assessment (written in 2013) as part of the Part-Night Lighting Consultation (see Appendix D).

Involvement and Engagement

The initial screen assessment for Option 1 (Part-Night Lighting) and Option 2 (All-Night Lighting, with additional options for dimming) has shown that further information is required regarding how Protected Characteristics are impacted upon by either option, in order that Cabinet Committee has enough information available to them to decide on whether to pick Option 1 or 2.

One source of data which will help Kent County Council identify any potential adverse impacts on Protected Characteristics as a result of Option 1 or Option 2 is via a public consultation.

A public consultation will take place between 21 September and 29 November 2015 and will consist of:

 A Consultation Document, which sets out the future options for street lighting

 2 x Focus Groups especially for Older Residents (i.e. Aged 70 and over)

 2 x Focus Groups with shift workers who travel to and from work after midnight and before 5.30am.

 Online questionnaire

 Paper questionnaire

 An Easy Read version of the Consultation Document and Questionnaire

 3 x Deliberative Events acros Kent with a representative sample of Kent residents

The consultation will be supported by a comprehensive Communications Plan, which will include:

 Direct mail/emails to key stakeholder groups

 Newspaper, radio and bus advertising

Updated 17/09/15 15  Press release and media briefings

 Advertising in Libraries and Gateways with hard copies of the consultation document and promotional postcard available

 Consultation document and promotional material provided to the Community Warden and Community Liaison Officer Team for distribution at the public meetings they attend

 Social media

 Invites to those registered with Kent County Council’s Consultation Directory

Updated 17/09/15 16 Potential Impact

Adverse Impact:

The initial screening assessment shows there is a potential adverse impact on the following Protected Characteristics is Option 1: Part-Night Lighting is chosen:

Aspect of Option 1: Part- Aspect of Option 1: Part- Protected Night Lighting (with Night Lighting that will impact Characteristic dimming) that will impact on group on group Age Disability Gender Gender Identity Race Street lights dimmed late at Street lights switched off late at night near places of night near places of worship worship may have an Religion or belief may have an impact on this impact on this Protected Protected Characteristic Groups Characteristic Groups sense of personal safety sense of personal safety Sexual orientation Pregnancy/maternity Managing Civil Partnerships Carers responsibilities Street lights dimmed late at Street lights switched off late at night in locations or areas night in locations or areas not not currently identified may All Protected currently identified may have an have an impact on all Characteristic impact on all Protected Protected Characteristic groups Characteristic Groups sense of Groups sense of personal personal safety or their safety or their personal personal mobility mobility

Positive Impact:

Updated 17/09/15 17 The initial screening assessment has not shown there to be any positive impact with regards to Option 1: Part-Night Lighting.

Adverse Impact:

The initial screening assessment shows there is a potential adverse impact on the following Protected Characteristics is Option 2: All-Night Lighting is chosen:

Aspect of Option 1: All- Aspect of Option 2: Night Lighting (with Protected Characteristic All-Night Lighting that dimming) that will will impact on group impact on group Age Disability Gender Gender Identity Race Religion or belief Sexual orientation Pregnancy/maternity Managing Civil Partnerships Carers responsibilities Street lights dimmed late at night in locations or areas not currently All Protected Characteristic identified may have an groups impact on all Protected Characteristic Groups sense of personal safety or their personal mobility

Positive Impact:

Updated 17/09/15 18 The table shown under the ‘beneficiaries’ section has shown that Option 2: All-Night Lighting will have a positive impact on All Protected Characteristics.

This is due to all roads, pavements, footpaths and access routes being lit late at night, meaning travelling through these areas is easier from a mobility point of view as well as a greater sense of personal safety in relation to crime.

JUDGEMENT

It is acknowledged that a number of Protected Characteristics will be impacted upon by Option 1: Part-Night Lighting, as switching off street lights in selected areas late at night will affect people’s personal mobility and have impact on their sense of personal safety.

To help mitigate people’s fears around personal safety, Kent County Council worked very closely with Kent Police as part of the 2013 Part-Night Lighting Project, using their crime statistics and experience to identify sites with a record of crime. These sites continue to be lit on an all-night basis. We have also excluded sites with a history of accidents. We are continuing to work with the police. If there is a negative effect on crime levels or road safety that can be attributed to the absence of street lighting the decision will be reviewed and lights may be turned back on.

Also as part of the 2013 Part-Night Lighting Project, there were a number of areas and locations considered not suitable for part-night lighting and a decision was made not to have their street lights switched off late at night (see section ‘Areas where street lights have not been switched off’).

It is acknowledged from the initial screening assessment that there maybe additional areas and locations that will need to be reviewed and possibly included on the list of areas not suitable for part-night lighting; taking into account the results of the public consultation should Option 1 be chosen.

It is also acknowledged from the initial screening assessment that further information is required regarding which Protected Characteristics may be affected by Option 1 along with how they are affected. The results of the public consultation will help with this should Option 1 be chosen.

Updated 17/09/15 19 (i.e. all Kent County Council owned street lighting are kept switched on all night long, with the option to dim the brightness of these lights during late evenings/early mornings).

It is acknowledged from the initial screening assessment that there maybe areas and locations that will need to be reviewed a list created of areas not suitable for dimming; taking into account the results of the public consultation should Option 1 be chosen.

It is also acknowledged from the initial screening assessment that further information is required regarding which Protected Characteristics may be affected by Option 1 if dimming is applied, along with how these Protected Characteristics are affected. The results of the public consultation will help with this should Option 1 with dimming be chosen.

Option 1 – Screening Sufficient NO

Option 2 – Internal Action Required NO

Option 3 – Full Impact Assessment YES

Only go to full impact assessment if an adverse impact has been identified that will need to undertake further analysis, consultation and action.

Initial EqIA - Sign Off

I have noted the content of the equality impact assessment and agree the actions to mitigate the adverse impact(s) that have been identified.

Senior Officer

Signed: Date: 18th September 2015 Name: Robert Clark Job Title: LED Streetlighting Programme Manager

DMT Member

Signed: Date: 18th September 2015 Name: Roger Wilkin Job Title: Interim Director of Highways, Transportation and Waste

Updated 17/09/15 20 Action Plan – Equality Impact Assessment as part of the pre-consultation/policy review stage (August 2015)

Protected Issues Identified Action to Expected outcomes Owner Timescale Cost Characteristic be taken implications

We will understand much Public There is insufficient clearer from a Protected consultation to information or data on the Public Characteristic’s perspective take place All Protected views of Protected consultation Cost to run a what the likely impact of Rob between Characteristics Characteristics with regards will be full public either Option 1 or Option 2 Clark 21 September – to Option 1 or Option 2 and required consultation will be along with their 29 November their thoughts on dimming thoughts on dimming with 2015 with either option either option.

Cabinet Committee will Until the results of the public review the public consultation consultation have been results and chose either reviewed by Cabinet Option 1 or Option 2 and Committee and a decision Cabinet whether to dim any street Cabinet All Protected made by them whether to Committee lights lit late at night. Committee Rob Characteristics go with Option 1 or Option 2 decision decision date: None Clark (and dimming with each), required The future direction of a new the direction of a new street street lighting policy will be To be confirmed lighting policy is not known known and a review of any and the impact on Protected impact on Protected Characteristics is not known Characteristics can then take place.

Updated 17/09/15 21 APPENDIX A: Kent County Council Street Lighting Policy for Kent (July 2010)

Kent County Council Street Lighting Policy for Kent

Kent Highway Services (KHS) provides and maintains street lights, lit signs and lit bollards for the benefit of highway users and to aid crime prevention. However, there is no statutory requirement on highway authorities to provide public lighting, therefore this policy document lays out the ways in which lighting is provided and maintained.

Energy and Carbon Emission

Kent Highway Services are committed to the reduction of energy consumption and CO 2 emissions through a variety of policy commitments:-

SL P1 - When installing new or when replacing existing units, energy efficient, low wattage ‘white’ lighting will be used. In specific locations ‘white’ light may not be appropriate, in these instances other energy efficient lighting will be used.

SL P2 – Newly lit streets or streets that are benefiting from replacement lighting will be designed to use the minimum amount of units or minimum energy consumption and will be assessed to consider if de- illumination, part night lighting, light dimming or removal of certain units is appropriate. These options will only be carried out after full consultation with the emergency services and representatives of the local community.

SL P3 – All streets in the County that are currently lit will be assessed and will be given a ‘lighting category’ from the British Standard for Street Lighting Design. Based on this category and other factors such as local amenities, night-time activity, traffic flows, community safety and crime levels. KHS will assess whether the same lighting level is required for the street all night and consider if de-illumination; part night lighting; light dimming or switch off and removal of certain units is appropriate.

SL P4 – All lit signs will be assessed to current standards and replaced with non illuminated signs where appropriate. All signs that remain lit will be lit during the hours of darkness only, using low energy units. Where accessibility for maintenance is difficult or expensive, long life lamps will be considered.

SL P5 – All lit bollards will be assessed to current standards and replaced with high-reflectivity, non- illuminated bollards where appropriate. All bollards that remain lit will be lit during the hours of darkness only, using low energy units. Where accessibility for maintenance is difficult or expensive, long life lamps will be considered.

SL P6 – All ‘mercury’ type units have been replaced with efficient low energy units (6300 units) during 2009-10.

Maintenance

Kent Highway Services are committed to maintenance in accordance with the principles set out in ‘Well-lit Highways – Code of Practice for Highway Lighting Management’. The following policies enable KHS to provide an effective maintenance regime

SL P7 – All reported faults will be assessed and visited with the intention of affecting a permanent repair within 28 working days (a permanent repair may not be possible on the first visit due to the need for specialist parts or because of electricity supply faults). If the unit is unlit because of an electrical supply fault the electricity supply company will be notified.

Updated 17/09/15 22 SL P8 – As appropriate, lamps will be bulk changed on a cyclical basis to ensure efficiency of maintenance and certainty of lighting.

SL P9 – The selection of new or replacement apparatus will take account of whole life cost, including repair, vandal resistance, energy consumption, other lighting styles in the vicinity and ongoing maintenance. Minimising environmental impact such as sky glow will also be a consideration.

SL P10 – All lit units and private cable installations will be the subject of an electrical test every 6 years in accordance with BS7671.

SL P11 – Structural testing of lighting columns will be carried out as recommended by the Institution of Lighting Engineers Technical Report No22, and ‘Well-lit Highways – Code of Practice for Highway Lighting Management’.

Efficiency and Cost Reductions

Kent Highway Services are committed to providing value for money for the residents of Kent. The cost of energy and maintenance is reviewed regularly and the following policies support the aims of an efficient street lighting service

SL P12 – The cost of energy for street lighting will be assessed and paid based on half-hourly meter readings.

SL P13 – The inventory of the Kent lighting stock will be completely reviewed by the end of June 2010 and continuously maintained to ensure unmetered electricity payments are correct, maintenance regimes can be planned accurately and future reductions can be targeted.

SL P14 – All redundant equipment will be assessed for potential reuse where appropriate, recycled or disposed in accordance with current waste disposal standards.

SL P15 – New technological developments and methods of working will be assessed and implemented if they are deemed appropriate and will ensure a sustainable lighting service.

Updated 17/09/15 23 APPENDIX B: Desktop exercise to help us understand how residents, businesses and those travelling through Kent interact with street lighting on a daily basis

Opening times Interaction with street lighting late at night Location (very approximate) Police stations 24 hrs All groups at night Road lay-bys 24 hrs All groups at night Showground’s/Events Parks 24 hrs All groups at night Taxi ranks 24 hrs All groups at night Sports grounds 7 – 7pm Closed at night time Adventure parks 7 – 7pm Closed at night time Support group locations 7 – 7pm Closed at night time Caravan / camping sites 24 hrs All groups at night Leisure centres 7 – 7pm Closed at night time Post offices 7 – 7pm Closed at night time Veterinarians 7 – 7pm Closed at night time Law Courts / Local Magistrates 7 – 7pm Closed at night time Military facilities 24 hrs Military personnel at night Houses (front and rear) 24 hrs All groups at night Mobile home/Travellers sites 24 hrs All groups at night Sheltered housing 24 hrs Workers, relatives, services and residents at night Residential homes 24 hrs Workers, relatives and services only at night Blocks of flats 24 hrs All groups at night Prisons 24 hrs Workers and services only at night Psychiatric institutions 24 hrs Workers and services only at night Hospitals 24 hrs All groups at night Banks / Building Societies 24 hrs Security staff only at night Accident & Emergency centres 24 hrs All groups at night Out-patients 7 – 7pm Closed at night time Nurseries 7 – 7pm Closed at night time Community support groups 7 – 7pm Closed at night time Day centres 7 – 7pm Closed at night time Registry offices 7 – 7pm Closed at night time Crematoriums 7 – 7pm Closed at night time Community Centres 7 – 7pm Closed at night time Town halls 7 – 7pm Closed at night time Village halls 7am – 2am Private parties, Firework events, wedding receptions etc. therefore all groups at night Public houses 11am – 4am All groups at night Restaurants 7am – 2am All groups at night Night clubs 24 hrs All groups at night Airports 24 hrs All groups at night Shopping malls 7 – 7pm Security staff only at night Industrial estates (shopping 7 – 7pm Security staff only at night malls) Industrial estates (business 7 – 7pm Security staff only at night parks) Garden centres 7 – 7pm Closed at night time

Updated 17/09/15 24 Petrol service stations 24 hrs All groups at night Car parks 24 hrs All groups at night Public parks / recreational 24 hrs Any that aren’t closed, then all groups at night grounds / open green spaces using Dentists 7 – 7pm Closed at night time Businesses (in town centres) 24 hrs Workers, services and customers Places of worship (churches, 24 hrs Access to religious places of worship during the mosques, gurdwara’s, night as part of religious requirements synagogues’ etc.) Alleyways 24 hrs All groups at night Alleyways (rear of houses) 24 hrs All groups at night Underpasses 24 hrs All groups at night Pedestrian footway/bridges 24 hrs All groups at night Bridges 24 hrs All groups at night Rural footpaths 24 hrs All groups at night Motorway slip-roads 24 hrs All groups at night Bus stops 5am – 2am All groups at night National cycle routes 24 hrs All groups at night Locks / canals 24 hrs All groups at night Ferry ports 24 hrs All groups at night Train stations 24 hrs All groups at night

Updated 17/09/15 25 APPENDIX C: Desktop exercise for use in the Initial Screening Assessment which helps us to understand how Protected Characteristics are affected by Option 1: Part- night lighting or Option 2: All-night lighting

For use with Option 1 (Part-night lighting) in the the table below, the following areas were considered not suitable for part-night lighting and so the street lights have not been switched off at night time:

1. Sites of potential road safety concerns 2. On some main traffic routes 3. Town centres 4. Locations with a significant night-time traffic record between about midnight and 5.30am winter time (1am to 6.30am summer time) 5. Areas identified by the police 6. Areas provided with local authority or police CCTV surveillance equipment 7. Areas with sheltered housing and other residences accommodating vulnerable people 8. Areas with a 24 hour operational emergency services site including hospitals and nursing homes 9. Formal pedestrian crossings, subways and enclosed footpaths and alleyways where one end links to a road that is lit all night 10. Where road safety measures are in place on the highway

Opening Protected Equality Characteristics Protected Equality times disproportionately affected by: Characteristics Location (very Option 1 – Part-Night Lighting disproportionately affected by: approximate) Option 2 – All-Night Lighting Police stations 24 hrs n/a – lights switched on all night (i.e. areas n/a identified by the police or provided with local authority or police CCTV equipment) Road lay-bys 24 hrs n/a – lights switched on all night (on some n/a main traffic routes and sites of potential road safety concerns) Showground’s/ 24 hrs n/a – not open late at night n/a Events Parks Taxi ranks 24 hrs n/a – lights switched on all night in town n/a centres Sports grounds 7 – 7pm n/a – not open late at night n/a Support group 7 – 7pm n/a – not open late at night n/a locations Adventure 7 – 7pm n/a – not open late at night n/a parks Caravan / 24 hrs n/a – camping site lights usually on 24 n/a camping sites hours and are privately owned Leisure centres 7 – 7pm n/a – not open late at night n/a Post offices 7 – 7pm n/a – lights switched on all night (i.e. areas n/a identified by the police or provided with local authority or police CCTV equipment) Veterinarians 7 – 7pm n/a – not open late at night n/a Law Courts / 7 – 7pm n/a – lights switched on all night (i.e. town n/a

Updated 17/09/15 26 Local centres, areas identified by the police or Magistrates provided with local authority or police CCTV equipment) Military 24 hrs n/a – lights switched on all night (i.e. areas n/a facilities identified by the police or provided with local authority or police CCTV equipment) Houses (front 24 hrs n/a – rural & some residential areas. n/a and rear) Lights switched on all night in town centre areas Mobile 24 hrs n/a – camping site are rural based where n/a home/Traveller there is no street light provision or street sites lights are privately owned Sheltered 24 hrs n/a – lights switched on all night (i.e. areas n/a housing with sheltered housing and other residences accommodating vulnerable people) Residential 24 hrs n/a – lights switched on all night (i.e. areas n/a homes with sheltered housing and other residences accommodating vulnerable people) Blocks of flats 24 hrs n/a – lights switched on all night (i.e. areas n/a with sheltered housing and other residences accommodating vulnerable people) Prisons 24 hrs n/a – lights switched on all night (i.e. areas n/a identified by the police or provided with local authority or police CCTV equipment) Psychiatric 24 hrs n/a – lights switched on all night (i.e. areas n/a institutions with sheltered housing and other residences accommodating vulnerable people, or 24 hour operational emergency services site including hospitals and nursing homes) Hospitals 24 hrs n/a – lights switched on all night (i.e. 24 n/a hour operational emergency services site including hospitals and nursing homes) Banks / 24 hrs n/a – lights switched on all night (i.e. areas n/a Building identified by the police or provided with Societies local authority or police CCTV equipment) Accident & 24 hrs n/a – lights switched on all night (i.e. 24 n/a Emergency hour operational emergency services site centres including hospitals and nursing homes) Out-patients 7 – 7pm n/a – not open late at night n/a Nurseries 7 – 7pm n/a – not open late at night n/a Community 7 – 7pm n/a – not open late at night n/a support groups Day centres 7 – 7pm n/a – not open late at night n/a Registry offices 7 – 7pm n/a – not open late at night n/a Crematoriums 7 – 7pm n/a – not open late at night n/a Updated 17/09/15 27 Community 7 – 7pm n/a – not open late at night n/a Centres Town halls 7 – 7pm n/a – not open late at night n/a Village halls 7am – 2am Applies to all Protected Characteristic n/a groups at night. Public houses 11am – 4am n/a – lights switched on all night (i.e. areas n/a identified by the police or provided with local authority or police CCTV equipment) Restaurants 7am – 2am n/a – lights switched on all night n/a (restaurants based in town centres only). Otherwise, applies to all Protected Characteristic groups at night. Night clubs 24 hrs n/a – lights switched on all night (i.e. areas n/a identified by the police or provided with local authority or police CCTV equipment) Airports 24 hrs n/a – lights switched on all night (i.e. areas n/a identified by the police, provided with local authority or police CCTV equipment or locations with a significant night-time traffic record between about midnight and 5.30am winter time (1am to 6.30am summer time)) Shopping malls 7 – 7pm n/a – not open late at night n/a Industrial 7 – 7pm n/a – not open late at night n/a estates (shopping malls) Industrial 7 – 7pm n/a n/a estates (business parks) Garden centres 7 – 7pm n/a – not open late at night n/a

Petrol service 24 hrs n/a – lights usually privately owned. Or n/a stations lights switched on all night as they are locations with a significant night-time traffic record between about midnight and 5.30am winter time (1am to 6.30am summer time) Car parks 24 hrs n/a – lights usually privately owned or n/a owned by the local borough/district council Public parks / 24 hrs n/a - Most parks close at night. Street n/a recreational lighting are usually around, not in the grounds / open middle of open green spaces/recreational green spaces grounds. Any lights in the middle are usually privately owned or owned by the local borough/district council Dentists 7 – 7pm n/a – not open late at night n/a Updated 17/09/15 28 Businesses (in 24 hrs n/a – lights switched on all night in town n/a town centres) centre areas

Places of 24 hrs n/a if located in town centre areas as n/a worship lights switched on all night. (churches, If located however in rural or other areas, mosques, then the ‘Religion’ Protected gurdwara’s, Characteristic may be disproportionaly synagogues’ affected, as entrances and exits to places etc.) of worship will be unlit street lights late at night. Alleyways 24 hrs n/a – lights switched on all night (i.e. n/a formal pedestrian crossings, subways and enclosed footpaths and alleyways where one end links to a road that is lit all night) Alleyways (rear 24 hrs n/a – lights switched on all night (i.e. n/a of houses) formal pedestrian crossings, subways and enclosed footpaths and alleyways where one end links to a road that is lit all night). If n/a – then applies to all Protected Characteristics. Underpasses 24 hrs n/a – lights switched on all night (i.e. n/a formal pedestrian crossings, subways and enclosed footpaths and alleyways where one end links to a road that is lit all night). If n/a – then applies to all Protected Characteristics. Pedestrian 24 hrs n/a – lights switched on all night (i.e. n/a footway/bridg formal pedestrian crossings, subways and es enclosed footpaths and alleyways where one end links to a road that is lit all night). If n/a – then applies to all Protected Characteristics. Bridges 24 hrs n/a – lights switched on all night (i.e. n/a formal pedestrian crossings, subways and enclosed footpaths and alleyways where one end links to a road that is lit all night). If n/a – then applies to all Protected Characteristics. Rural footpaths 24 hrs n/a – lights switched on all night (i.e. n/a formal pedestrian crossings, subways and enclosed footpaths and alleyways where one end links to a road that is lit all night). If n/a – then applies to all Protected Characteristics. Motorway slip- 24 hrs n/a – lights switched on all night (i.e. sites n/a roads of potential road safety concerns, locations with a significant night-time traffic record between about midnight

Updated 17/09/15 29 and 5.30am winter time (1am to 6.30am summer time), some main traffic routes, or where road safety measure are in place on the highway) Bus stops 5am – 2am n/a – lights switched on all night (i.e. sites n/a of potential road safety concerns, locations with a significant night-time traffic record between about midnight and 5.30am winter time (1am to 6.30am summer time), some main traffic routes, where road safety measure are in place on the highway or located in a town centre) National cycle 24 hrs n/a – lights switched on all night if on a n/a routes main traffic routes, or if in a location with a significant night-time traffic record between about midnight and 5.30am winter time (1am to 6.30am summer time). If n/a, then it applies to all Protected Characteristics. Locks / canals 24 hrs n/a – lights switched on all night if the n/a area has been identified by police. If n/a, then it applies to all Protected Characteristics. Ferry ports 24 hrs n/a – lights switched on all night if the n/a area has been identified by police, on a main traffic routes, or if in a location with a significant night-time traffic record between about midnight and 5.30am winter time (1am to 6.30am summer time), or provided with local authority or police CCTV equipment. If n/a, then it applies to all Protected Characteristics. Train stations 24 hrs n/a – lights switched on all night if the n/a area has been identified by police or provided with local authority or police CCTV equipment. If n/a, then it applies to all Protected Characteristics.

Updated 17/09/15 30 APPENDIX D: Initial Screening Assessment from the Part-Night Lighting Equality Impact Assessment 2013

Screening Grid

Could this policy, Assessment of Provide details: Could this policy, procedure, project procedure, project or potential impact a) Is internal action required? If yes what? or service promote equal service affect this group HIGH/MEDIUM opportunities for this group? Characteristic less favourably than others LOW/NONE b) Is further assessment required? If yes, YES/NO - Explain how good practice in Kent? YES/NO UNKNOWN why? can promote equal opportunities If yes how? Positive Negative The exception criteria recognise that the proposals could have a disproportionate adverse impact on elderly or vulnerable people, particularly in emergency situations such as ambulance call-out. For this reason all-night, Yes lighting will be maintained in areas with sheltered Age Med Low housing and other residences accommodating vulnerable people. All-night, lighting will also be maintained in areas with 24hr operational emergency services sites including hospitals.

The exception criteria recognise that the proposals could have a disproportionate adverse impact on those with a disability, particularly in emergency situations such as ambulance call-out. For this reason all-night lighting will Yes Med Low Disability be maintained in areas with sheltered housing and other residences accommodating vulnerable people. All-night, lighting will also be maintained in areas with 24hr operational emergency services sites including hospitals.

Gender No None None

Gender No identity None None

Updated 17/09/15 31 Race No None None

Religion or No None None belief

Sexual No orientation None None

Maternity: All-night, lighting will be maintained in areas Pregnancy No None None with 24hr operational emergency services sites including and maternity hospitals.

Marriage and No Civil None None Partnerships

Updated 17/09/15 32